Procedure Subject: Hazardous Waste Management Plan Areas Affected: Departments the generate hazardous waste. Effective: 1/1/09 Reviewed/Revised: 11/24/09 1.0 Purpose, Applicability, and Scope 1.1 Purpose (Include regulatory requirements) - The purpose of this procedure is to provide a framework for those individuals on campus who generate or handle hazardous waste. Consult title 40 Code of Federal Regulations or Environmental Health and Safety for additional information regarding hazardous waste. 1.2 Applicability This shall apply to all students, staff and faculty on the Knoxville campus of the University of Tennessee. 1.3 Scope This standard applies to all hazardous waste as defined in section 2.2 below. 2.0 Abbreviations, Acronyms, and Definitions 2.1 Abbreviations/Acronyms DOT Department of Transportation EHS Environmental Health and Safety IATA- International Air Transportation Agency 2.2 Definition Hazardous Waste - Hazardous waste is a waste with properties that make it dangerous or potentially harmful to human health or the environment. The universe of hazardous wastes is large and diverse. Hazardous wastes can be liquids, solids, contained gases, or sludges. They can be the by-products of manufacturing processes or simply discarded commercial products, like cleaning fluids or pesticides. In regulatory terms, a RCRA hazardous waste is a waste that appears on one of the four hazardous wastes lists (F-list, K-list, P-list, or U-list), or exhibits at least one of four characteristics ignitability, corrosivity, reactivity, or toxicity. Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA) Subtitle C. Hazardous Waste Management Plan Page 1
3.0 Roles and Responsibilities The management of hazardous chemical waste at the University consists of the coordination and direction of the waste generated in hundreds of laboratories and other campus facilities. To manage this large volume effectively, it is necessary to use the services and technical expertise of the Environmental Health and Safety (EHS), faculty and staff members. This section briefly describes the function of each group and its role in the hazardous chemical waste management program. a. University Administration The chancellor of the University is responsible for the administration of policy pertaining to institutional safety and health-related matters. The chancellor oversees the administration of safety policies through the chain of authority within the institution, delegating to deans, department heads, principal investigators and supervisors the responsibility for ensuring safe work practices of those under their supervision and adherence to established policy and guidelines. b. EHS EHS is responsible for surveillance of all laboratory activities involving the use of toxic agents and all additional chemical and biological problem areas within the confines of the University. A list of staff members from EHS is available as attachment A. Specific duties of the department include: a. Monitor the implementation of the safety and health policies of the University; b. Design and improve disposal procedures for chemical waste materials; c. Prepare, submit, and maintain records, reports and manifests as required by government regulations; and d. Prepare applications for state and federal permits to generate and properly dispose of hazardous chemical waste. e. Schedule and co-ordinate the activities of the hazardous waste contractors on campus. c. Principal Investigator, Classroom Instructor or Supervisor The principal investigator, classroom instructor, or supervisor has the direct responsibility for assuring that the policy and guidelines established herein are followed by all personnel, including other researchers under their jurisdiction. d. Laboratory Worker and Other Individuals Hazardous Waste Management Plan Page 2
The success of the hazardous chemical waste management program at the University is dependent on the conscientious efforts of the individual laboratory worker and staff employee. Because the laboratory workers frequently handle hazardous chemicals, it is essential that they follow the advice, policies, and procedures pertaining to hazardous materials handling. The individual staff members are expected to: a. Dispose of all chemical waste in accordance with established procedures set forth in this disposal guide; b. Maintain the identity of all chemicals with which they work; c. Package and label surplus and waste chemicals in accordance with established procedures set forth in this disposal guide; and d. Seek the advice, when necessary, of EHS concerning the proper handling and disposal of hazardous chemicals. 4.0 Procedures Packaging a. All containers must be leak-proof and chemically compatible with their contents. Lids should fit properly and be tightly secured so that the container could be turned upside down without fear of a spill; b. Bags may be used only for dry solids. Needles (capped or uncapped), pipettes, broken glass or other sharp-edged materials are not acceptable in bags. All "sharps" should be placed in puncture-resistant containers; c. Containers which show signs of contamination on their exterior are not acceptable regardless of their contents. EHS must take every step available to protect its staff from potential chemical hazards; d. Containers marked with biohazard or radioactive warnings are not acceptable for chemical waste disposal. Neither are the orange and red disposal bags designed for disposal of these two types of hazards: e. Each container must be marked with all information discussed in the labeling section; and f. Minimize void space in containers by assuring that collection containers are filled to capacity before requesting disposal or combining two containers of identical material into one. Labeling In order to comply with state and federal regulations and University policy, the following information must appear on each container of hazardous waste. a. "Hazardous Waste": State and federal regulations require that each container be clearly marked with the words, "Hazardous Waste". Hazardous Waste Management Plan Page 3
b. Generator's Name: The individual who is responsible for the area or process from which the waste originated and the best person to contact if further information about the material is needed. c. Chemical Constituents: Give all constituents whether hazardous or no hazardous. Formulas, trade names, and abbreviations are not acceptable. Always give percentage of constituents. Estimates are acceptable. Storage a. Any container used for disposal and storage of waste must be marked with the information specified in the Labeling section immediately upon placing the first drop of waste into the container. Do not fill in the date section; this will be completed by EHS. b. All containers must be closed with a tight-fitting lid. It is illegal to store waste in an open container. c. Whenever possible, store flammable waste liquids and waste corrosive liquids in cabinets designed for these materials. 5.0 Recordkeeping EHS shall serve as the primary location for records related to hazardous waste. Records shall be maintained on the following a. Hazardous waste manifests b. Annual reports c. Land disposal restrictions d. Waste stream profiles e. Waste determinations f. Disposal certificates g. Waste Minimization Plan h. Emergency Contingency Plan i. Training i. DOT Hazardous Material Shipping ii. IATA Hazardous Materials Shipping iii. OSHA Hazardous Waste Operations j. Communiqués from and to: i. Regulatory agencies ii. Hazardous waste vendors iii. Generators of hazardous waste iv. University administration Most of these records must be maintained for three years to meet regulatory requirements. However to be prudent these records will be kept indefinitely. Hazardous Waste Management Plan Page 4
Training records shall be maintained by the individual department who whom the employee or student reports. Training records may also be kept in the IRIS. 6.0 Training and Information Requirements The director of EHS shall ensure that select staff members in the department are adequately trained in the following subjects: a. Hazardous substances b. DOT and IATA shipping requirements c. Hazardous waste management d. Personal protective equipment e. OSHA Hazwopper e. Procedure for submitting the annual report to the Tennessee Department of Environment and Conservation Department heads having individuals (staff, faculty and students) under their control who generate hazardous waste shall ensure these individuals have been trained. Training is available from EHS in the form of traditional classroom, self-study PowerPoint or online with Skillsoft. 7.0 Attachments See attachment A below 8.0 Associated Standards OSHA 29 CFR 1910.120 (Hazardous Waste) EPA 40 CFR 260-270 (Hazardous Waste) Hazardous Waste Management Plan Page 5
Attachment A WASTE MANAGEMENT CONTACTS ENVIRONMENTAL HEALTH AND SAFETY Mark Smith - Director / Certified Hazardous Materials Manager / Certified Industrial Hygienist / Certified Safety Professional The Director is responsible for the overall coordination of the Hazardous Materials Management Program. Chuck Payne - EHS Team Leader / Certified Hazardous Materials Manager The EHS Team Leader provides expertise in the area of Hazardous Materials Safety and Health Protection Practices. April Case Senior Environmental Coordinator/ Certified Hazardous Materials Manager The hazardous materials manager is responsible for the direct coordination of the Waste Management Program and laboratory inspection. Pam Koontz - Senior Laboratory Safety Coordinator/ Certified Hazardous Materials Manager The hazardous materials manager is responsible for the direct coordination of the Waste Management Program and laboratory inspection. Suzanne Rimmer - Technical Supervisor III The Safety Inspection supervisor provides expertise in fire protection, coordinates the first aid fire protection equipment (fire extinguisher) maintenance and inspection program. Jim Walker - Senior Safety Coordinator Provides assistance to the hazardous materials manager. Kim Harmon - Program Resource Specialist In addition to clerical support, the departmental senior secretary provides administrative assistance to all the staff members. Hazardous Waste Management Plan Page 6
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